Comment Log Display

December 2, 2008

Clerk of the Board
Air Resources Board
1001 I Street
Sacramento, California 95814

Re: December 11 and 12, 2008 Hearing:
RULEMAKING TO CONSIDER ADOPTION OF A REGULATION TO REDUCE
GREENHOUSE GAS EMISSIONS FROM HEAVY-DUTY VEHICLES

Central Valley Trailer Repair (CVTR) requests that the California
Air Resources Board (ARB or Board) not make mandatory the proposed
requirements for trailers based on the U.S. Environmental
Protection Agency (EPA) SmartWay Partnership Program. 

Under the SmartWay program, the U.S. EPA certifies tractors and
trailers that have been demonstrated to be more fuel efficient than
their traditional counterparts. At this time, there are SmartWay
specifications for tractors with sleeper cabs and for 53-foot or
longer dry-van trailers, and therefore, only these products can be
certified by original equipment manufacturers under the SmartWay
program. The SmartWay program also approves individual aerodynamic
equipment for trailers and efficient (low-rolling resistance) tires
for tractors and trailers.

According to the EPA, “SmartWay is positioned as a personal choice
that can make a difference for the environment.” CVTR believes
these actions should remain a choice, not a mandate.

Founded in 1984 CVTR has two locations in the Central Valley,
Stockton and Fresno. We serve the trucking industry by selling and
servicing our customers equipment needs. We have just over 60 full
time employees. 

Background

In 2006, California enacted The Global Warming Solutions Act (AB
32) to address climate change issues within the state. The
legislation requires the Board to develop programs to reduce
greenhouse gas emissions to 1990 levels by 2020. To begin
fulfilling the commitments made in AB 32, ARB has developed a list
of discrete early action measures. 

In 2007 the Board approved a list of nine discrete early action
measures that are scheduled to be adopted by the Board and
enforceable by January 1, 2010. The list included a measure
entitled: “SmartWay Truck Efficiency.” The proposed regulation
referenced above is designed to implement this measure. The
proposed regulation would apply to both California-registered and
out-of-state-registered tractors and trailers. It relies on the
voluntary federal EPA SmartWay program to establish mandatory
California tractor and trailer requirements. 

Cost of the Proposal

According to the ARB STAFF REPORT: INITIAL STATEMENT OF REASONS
FOR PROPOSED RULEMAKING, “While compliance with the proposed
regulation would require an initial capital cost, it is expected
that a cost savings would ultimately result due to the increase in
HDV fuel efficiency and the resultant usage of less fuel.” The
report estimates the average cost of trailer compliance for the
initial purchase and installation of aerodynamic technologies and
low-rolling resistance tires is approximately $2,900 per trailer.
In addition, annual maintenance costs for inspection and repair of
installed aerodynamic technologies, and replacement and retread
costs for low-rolling resistance tires, is estimated to be about
$120 for the trailer. 

I have to take issue with these figures.  In the report itself
staff notes that the fleets they chose to interview reported side
skirts alone costing as much as $2,600. In addition to the side
skirts the regulation would require SmartWay approved low-rolling
resistance tires and either front or rear fairings. 

The report flatly states that “In the real world it is difficult
to isolate the benefits achieved using one particular aerodynamic
technology from all other fuel-saving strategies and technologies
that may be used.”

On the benefits side of the equation the staff report’s data is
similarly incomplete. The analysis for vehicle usage takes
estimated vehicle miles traveled (VMT) and assumes that a very high
percentage of those miles are at highway speeds. In Table XII-3:
Annual Operating Cost Savings of the report staff used the
assumption that 84 percent of the vehicle miles traveled are at
highway speed. The fuel efficiency improvements of currently
certified aerodynamic devices are determined from track tests
conducted at speeds of 60 to 62 miles per hour according to “SAE
J1321 Type II” test procedures. 

While the staff reports calculates the benefits of this proposal
for vehicles traveling 60 to 62 miles per hour, the speed limit for
trucks in California is 55 miles per hour, assuming traffic
conditions allow for traveling at the speed limit. I question
whether the staff report data is reflective of the real world
conditions typically experienced in the state of California. It
appears that the report’s analysis clearly overstates the monetary
benefit that would actually be experienced.

Additionally, the report indicates that the VMT data the staff
were able to obtain cannot be directly applied to the fuel
efficiency improvements they show as VMT is accrued at various
speeds, while the fuel efficiency improvements are determined at
speeds of approximately 60 miles per hour. The report then clearly
states, “…the
speed-VMT distribution of the impacted tractors and fuel
efficiency improvements at different speeds are needed in order to
accurately quantify the GHG emission benefits. However, such data
were not available and therefore staff estimated the GHG benefits
using only the VMT accrued at highway speeds, without taking into
account benefits that occur at lower speeds.”

Trucks traveling at higher rates of speed are likely to obtain
much greater fuel savings from the proposed aerodynamic equipment
than while traveling at lower speeds.

Further, I question the estimates used in the analysis for the
number of trailers likely to be affected by the proposed
regulation. As the report indicates, “for trailers, no database
exists that provides a complete inventory on the total number of
box-type trailers that would be impacted by the proposed rule.”
Staff then simply chose to estimate a ratio for the number of
trailers to tractors and extrapolate a figure.

Conclusion

The report’s cost/benefits analysis relies on incomplete data. The
number of trailers likely to be affected is conjecture. The cost
estimates of compliance for each affected trailer are unreasonably
low. The benefits are certainly inflated due to inaccurate
estimates of the speed at which the vehicles typically travel. 

In the discussion of costs and user concerns many conclusions seem
to be based on a small sampling of anecdotal evidence. Also, there
appear to be a great many statements that begin, “staff anticipates
that…” It is clear that the staff is counting on numerous instances
of future improvements and developments to be carried out by the
private sector in order to make this regulation viable. 

It is unreasonable to approve a regulation whose implementation
and benefits are unknown and dependant on future occurrences which
may or may not happen.

While the goal of greater fuel economy and reduced emissions is
laudatory, more testing and analysis is required before placing
such a significant financial burden on the businesses shipping and
carrying goods to and from California. 

I think the TRU ATCM is the perfect example of a rule that was put
together in haste with out enough real world testing.         In
that rule the available technology was not available to meet the
requirements of the rule and in some cases are still not available.
Don’t take the word of vendors using tests that prove only that one
product is superior to another in a particular situation. The real
world of transportation is too diverse to say that one fix will
work for all aspects of the industry. Vendors won’t tell you that.
Our industry is very interested in seeing that the goals of the
CARB are achieved but can only do so in an economically viable way.
 This is not the right rule for California to lead the rest of the
country with.  Just like the TRU ATCM  so please send this rule
back to staff and urge them to work with Industry to achieve the
goals you have set. 

Sincerely,



Mike Shuemake
President
Central Valley Trailer Repair Inc.